ATF Ruling 2021R-05F FastBound compliance checklist

Definition of Firearm, Frame and Receiver

  • The term “frame” now means the part of a handgun or “variants” (also a defined term) using a handgun design, that provides housing or a structure for the sear or equivalent—that part that holds back the hammer, striker, bolt, or similar component prior to firing.

The definition of “frame” has been updated in FastBound.

  • The term “receiver” means the part of a rifle, shotgun, or projectile weapon other than a handgun, or variants, that provides housing or a structure for the bolt, breechblock or other primary component designed to block or seal the breech prior to firing.

The definition of “receiver” has been updated in FastBound.

Recordkeeping Requirements

  • The final rule requires all licensed manufacturers and importers to consolidate their records of manufacture, importation, acquisition, and disposition of firearms.

All records are kept in one A&D and can be filtered by Acquire Type.

  • The final rule requires ALL licensees to eliminate duplicate recordkeeping entries.

    • In the event the licensee records a duplicate entry with the same firearm and acquisition information, whether to close out an old record book or for any other reason, the licensee shall record a reference to the date and location of the subsequent entry (e.g., date of entry, book name/number, page number, and line number) as the disposition.

FastBound uses a Notes column for the audit trails on the Bound Book report.

  • The final rule clarifies that licensed dealers (including gunsmiths), manufacturers, and importers may conduct same day on the spot adjustments or repairs to firearms without recording them as acquisitions or dispositions, provided they are returned to the person from whom they were received on the same day.

Same day returns must not be logged into FastBound.

Recording information into the A&D record

  • Manufacturers MUST record the acquisition of GCA firearms manufactured or otherwise acquired within seven (7) days, or prior to disposition, whichever is sooner.

FastBound allows items to be acquired with past dates, but not future dates.

  • If there is more than one manufacturer or importer, country of manufacture, or serial number marked on a firearm–

    • Licensees MUST record all firearms markings in the A&D record.

When an item has more than one Manufacturer or one Importer FastBound allows them to be entered with a slash “/” between them.

  • Any FFL number either as a prefix, or if remanufactured or imported, separated by a semicolon, placed on a firearm, must be included in the serial number recorded in the A&D record.

FastBound allows items with multiple serials to be entered with a slash “/” between the serial numbers.

  • All firearms acquired by an FFL, except for same day adjustments or repairs returned to the same person, must be recorded as an “acquisition,” in the A&D record.

Same day returns must not be logged into FastBound.

Bound Book Header

  • Update the format required for the record of receipt and disposition of firearms

FastBound uses the format in the regulation with a Notes column for the required Audit Trails.

Type 01 and 02 FFL’s (Dealers)

Type 07, 08, 09, 10, 11 (Importers and Manufacturers)

NFA Requirements

  • Manufacturers MUST record NFA firearms in the A&D Record by close of the next business day unless there is a sufficient commercial record of acquisition, in which case the grace period to record would be extended until the seventh day.

FastBound allows items to be acquired with past dates, but not future dates.

Record Retention

  • The final rule requires that ALL licensees MUST retain ALL required records (A&D Records and ATF Forms 4473) until the business or licensed activity is discontinued. A&D records must be kept either on paper or in an electronic alternate method approved by the Director, at the licensed business premises readily accessible for inspection.

All A&D records are maintained in accordance with ATF Ruling 2016-1.

  • The final rule made changes to § 478.50(a) to make clear that a warehouse may be used for the storage of paper records over 20 years of age.

Paper records are stored outside of FastBound.

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